This is a summary of Aegon UK's (AUK) policy on how it manages conflicts of interest overall across its UK business. A conflict of interest may arise where an action taken by us could be seen to compromise or conflict with the best interests of our advisers and customers.

Conflicts can also arise as a result of AUK’s commitment to responsible investing, in particular in relation to Stewardship (the responsible allocation, management and oversight of monies to create long-term value for customers, leading to sustainable benefits for the economy, the environment and society) and the Stewardship Code.

We’re completely transparent about where conflicts of interest can arise and our policy to deal with them.

Business entertainment and gifts

From time to time we may receive or provide corporate hospitality and gifts from/to service providers and suppliers. We may also receive these from financial advisers. We have a strict policy regarding the receipt or provision of gifts and business entertainment. A disciplinary process may be enforced if this policy isn't strictly adhered to.

Client data

We expect high standards of performance and integrity from our staff. This is embedded in our way of working and is detailed in our procedures. Any breaches of our procedures are investigated and managed through our Disciplinary Policy.

Stewardship

We have a Conflicts of Interest policy which outlines examples of Stewardship conflicts, the mitigants in place to address such conflicts, and the process which should be followed to report any instances which may occur.  

Stewardship conflicts may arise due to the potential tensions between AUK’s role as an asset owner, its business as a pension provider, as well as its position as a separate legal entity operating within a Group working with asset managers as well as other service providers.

- Conflicts from being part of a Group
When interacting with other members of the Aegon Group, such as Aegon Asset Management or Aegon NV, AUK must take care to ensure that it does not interact in a different or more favourable manner with these entities than it would from any other partner. Relevant mitigants are in place to address this. 

- Conflicts from being a Pension Provider
Liaising with investee companies that may also be a client, or a potential client could have the potential to impair the commercial relationship with that company. Relevant mitigants are in place to address this.

Third-party fees

To enable our investment services, parts of Aegon may pay fees to third parties for services relating to the maintenance of investor accounts. Fees may also be paid to third-party technology providers who offer investors access to trade on our platforms through their financial advisers’ website.

Financial adviser benefits

We may provide certain monetary and non-monetary benefits to financial advisers who use our platforms. These benefits are provided on the strict understanding that they’ll enable financial advisers to:

• improve and extend the range of services provided to customers, and
• provide greater opportunity to pass savings on to customers by discounting funds, rebating commissions or reducing fees.

We have a strict policy regarding the frequency and cost of the benefits provided to financial advisers.

1. Monetary benefits

We may contribute towards our share of financial advisers' costs to promote our propositions and services at events, or through marketing activity.

2. Non-monetary benefits

Minor non-monetary benefits may also be provided to financial advisers at no charge. These can include:

• Tools to help them provide financial advice on our services and the products we distribute.
• Technical training on the use of our platform and their associated facilities.
• Integration of their computer systems and websites with our platforms.
• Meetings including reasonable and appropriate hospitality, round-table discussions and marketing support.
• Exposure to market updates and fund manager commentary at conferences and other events.

Further Information

If you have any questions about our Conflicts of Interest Policy, please get in touch with us.